Proportionality in company penalty quantification requires aggravating and mitigating factors; mechanical multiplication of director liability is impe...
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Revision under section 263 failed because CSR expenditure cannot be added to book profit under section 115JB except through the specific adjustments in the Explanation, and the Assessing Officer had no power to alter the audited accounts beyond those statutory items. The Tribunal also held that a section 14A read with Rule 8D disallowance cannot be imported into MAT book profit when tax liability is determined under section 115JB, so the omission to examine that issue caused no prejudice to the Revenue. As neither ground made the assessment order both erroneous and prejudicial, the revisionary order was quashed.
Revision under section 263 failed because CSR expenditure cannot be added to book profit under section 115JB except through the specific adjustments in the Explanation, and the Assessing Officer had no power to alter the audited accounts beyond those statutory items. The Tribunal also held that a section 14A read with Rule 8D disallowance cannot be imported into MAT book profit when tax liability is determined under section 115JB, so the omission to examine that issue caused no prejudice to the Revenue. As neither ground made the assessment order both erroneous and prejudicial, the revisionary order was quashed.
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